Knowingly and willfully conspiring to injure, oppress, threaten, and intimidate persons in the free exercise and enjoyment of the rights and privileges secured to them by the Constitution and laws of the United States, that is, the right to be free from involuntary servitude secured by the Thirteenth Amendment to the United States Constitution, all in violation of 18 U.S.C. § 241.

Defendants convinced victims to leave China to work as cashiers in Wang's American grocery store. Wang agreed to arrange travel and papers for a sum of $1,875 each. Upon arrival, defendants confiscated victims' passports and return tickets. The victims were taken to Bao Lai, a restaurant and brothel owned by Kuo, where they were kept, locked in. Victims were made to work as prostitutes to pay for their travel expenses, and were threatened with food deprivation, beatings, and harm to their families in China. Defendants eventually escaped and reported to the police station, where they filed their reports and were sent to a hospital. Defendants pleaded guilty in response to a plea agreement. The district court imposed terms of incarceration and filed a motion for restitution.